Implication of International Laws Enforcement on Banks (De-Risking, AML/CFT Compliance)
2 – 3 May 2016 MANAMA – KINGDOM OF BAHRAIN
BACKGROUND
With the increasing challenges of compliance in the new regulatory framework, banking institutions, small and large, have found themselves subject to an overabundance of complex regulations governing every aspect of their business.
This complexity and required thoroughness in screening clients have rendered the basic tools like KYC (Know Your Customer) primitive, and forced banks into more mature AML Tools such as Enhanced Due Diligence and Risk-Based Compliance in order to deal with customers that pose higher money laundering or terrorist financing risks. Alternatively, in the absence of the will to use these mature tools, or in the presence of fear of a balance-sheet shaking penalty; other banks resorted, instead, to De-Risking.
Therefore, De-risking has become common shorthand for referring to any instances in which banks have adopted increasingly stringent financial crime-related policies to reduce their exposure to potential money laundering, terrorist financing, corruption and sanctions risk. More specifically, it relates to the strategies adopted by banks to reduce their risk.
This complexity means that de-risking manifests itself in a number of ways. The most notable example is a bank ceasing to provide accounts to certain customer or product sectors. Total withdrawal from a specific sector or customer group is at the farthest end of the de-risking spectrum. More frequent responses include:
– Banks Especially global banks, limiting their exposure to certain higher risk customer sectors e.g. Money Service Businesses.
– Taking steps to avoid an over concentration to a particular type of risk e.g. Correspondent Banking.
– Limiting the types of services offered to higher risk relationships e.g. cash clearing activity, bank notes etc.
– Curtailing certain products and services in and for certain countries and customer sectors
As a result, retail and commercial customers have been highly impacted leading such customers to seek alternative banking services that are less supervised and may involve higher Money Laundering risks.
The Wholesale De-risking approach to De-risking seems to contradict the financial inclusion concept being promoted by the FATF to provide financial Institutions to less privileged persons who do not have access to banking services.
This Forum will provide an assessment of De-risking in addition to its implementation and the impact of that on the banking and financial sectors, non-financial sector, and customers in general.
OBJECTIVES:
At the completion of this significant Forum, the attendees will have a profound knowledge of the following:
– Proportionate and effective implementations of de-risking concept.
– How local banks have been impacted by the wholesale de-risking, imposed by correspondent banks.
– Sanctions challenges, when coupled with de-risking enforcement.
– Aligning of de-risking with the risk based approach in an AML program.
MAIN TOPICS
– Key elements of an effective compliance program and the regulator’s focus
– Compliance Program – RBA in today’s Environment
– Challenges and Tools for Effective Compliance
– Meeting Evolving Compliance Standards
– Sanctions and Enforcement: What’s Changed and What Hasn’t Changed as a Result of the Iranian Nuclear Deal”
– De-Risking: Causes, Impact, Control and Consequences
– How to prepare for a regulatory examination and pitfalls of poor preparation?
– De-Risking and the Inherent Risks
– De-risking vs Risk Based approach impact on exchange companies / money transmitters and charities.
– Compliance: What to Look for, and Suggestions for Improvement.
– De-Risking and correspondent Banking Relations
– De-risking, a Bahrain/GCC Perspective.
SPEAKERS:
Mr. Ajay Badyal
Mr. Badyal heads the Assurance & Advisory Services Unit of the Compliance Function at the Federal Reserve Bank of New York. The unit is responsible for evaluating the Compliance Frameworks of globally-recognized financial institutions. In previous assignments, he has managed teams of specialist examiners and technical experts who supervised the US operations of complex global financial institutions. He has also managed cross-functional teams in evaluations of complex strategic projects such as the forensic examinations of troubled banks and the adequacy of Anti-Money Laundering and Counter-Terrorism programs. He has developed and written supervisory guidance.
Mr. Badyal has designed and presented many specialized training programs, particularly in the areas of credit risk management, capital markets trading, derivative products, internal controls, risk-focused supervision, anti-money laundering, fraud and corporate governance for both the FRBNY and the Board of Governors of the Federal Reserve System. He also has extensive international experience in banking, commodity trading and shipping.
Mr. Mohamad Mansour
Senior AGM & Chief Compliance Officer at the Commercial Bank of Qatar, since 2005 .
A seasoned and certified compliance professional (CAMS/CCO, started his career in the USA in the domain of finance and management with both government & private sectors. Joined the Central Bank of Lebanon in 1997 as a Senior Officer at Treasury Department, and in 2000 moved on to become a founding member of Lebanon’s Financial Information Unit – also known as The Special investigation Commission. During his tenor with the FIU he was assigned as a Senior Investigator and Research Analyst, where he led numerous ML&TF investigations with regional and international counterparts, as well as conducted banks’ ML & TF examination programs, and represented Lebanon in multiple FATF and Egmont Group meetings. He currently manages Commercial Bank’s Group Compliance program, and is highly engaged with regional regulators and private sector entities on AML Compliance initiatives and training programs.
Mr. Mahmoud Fadlallah
Counsel, Akin Gump Strauss Hauer & Feld LLP / Dubai, United Arab Emirates & Washington, DC, USA.
Mr. Fadlallah is an attorney in Akin Gump’s international trade compliance and investigations practice, based primarily in Dubai. His practice focuses on advising non-U.S. entities on compliance with applicable financial sanctions and other restrictive measures, including those administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). Mr. Fadlallah speaks regularly on various sanctions topics and their effect on companies and financial institutions in the Middle East, and has conducted trainings for compliance professionals and in-house legal teams on implementing effective compliance programs to mitigate sanctions-related risks. Most recently, Mr. Fadlallah has spoken at conferences and private forums on the impact of the Iran nuclear deal on the region.
Mr. Fadlallah is a graduate of the University of Michigan (B.A.) and the University of Minnesota Law School (J.D.). He is a member of the New York and District of Columbia bars.
Mr. Chahdan E. Jebeyli
General Manager, Group Head Legal & Compliance, Bank Audi s.a.l.- Beirut, Lebanon
He is a member of the Group Executive Committee, Chairman of the Compliance Officers Committee of the Association of Banks in Lebanon, and President of Compliance Officers Committee at the World Union of Arab Bankers.
Prior to joining Bank Audi in 1997, he was the Managing Director for Legal & Compliance at Citibank – Middle East & North Africa. Before Citibank, he was in private legal practice in the USA with focus on commercial and banking matters.
He is a former Lebanese Judge and a member of the N.Y. and American Bar associations. He has an LLM in International Banking from Boston University, School of Law.
Experts from the Central Bank of Bahrain
Experts from the Bahrain banking sector
PARTICIPATION FEES:
800 $ for UAB members
1000 $ for Non-UAB members
Fees include attending the forum, receiving the material, refreshments and a daily lunch.
SCHEDULE AND LANGUAGE:
Registration: the first day from 8am to 9 am.
Schedule: from 9:00 am to 14:00 pm daily.
Forum language: English
MEANS OF PAYMENT:
A Bankers check shall be drawn at New York to the order of the Union of Arab Banks, or by transfer to the account of the UAB No: 0331-082305/510 Arab Bank – Beirut Lebanon.
For online registration & payment, please visit our website :www.uabonline.org
Arab Bank – Beirut – Lebanon Swift code (ARABLBBX)
Riyad El solh Br. Account No:0331-082305-510
Through Wells Fargo – Sanfrancisco – USA Swift code (PNBP US 3N NYC)
Iban: LB42 0005 0000 0000 3310 8230 5510
Beneficiary: Union of Arab Banks
For any additional information or inquiries regarding this event, please contact us at the following addresses:
Union of Arab Banks
Headquarters:
Beirut – Lebanon: P.O. Box: 11-2416 Riad El-Solh 1107 2210
Tel: +961-1-377800 – +961-1-364881 – 5 – 7 Fax: +961-1-364952 – +961-1-364955
Email: uab@uabonline.org
e-mails: training@uabonline.org workshops@uabonline.org Booking online: www.uabonline.org
Regional Offices:
Cairo – Egypt : 19 Al-Batal Ahmed Abdelaziz Str. 2nd Floor – Apt (11) – Mohandissine – Giza
Tel: +202-33023762/+202-33034442 Fax: +202-33440297
Email: uab-egypt@uabonline.org
Amman – Jordan: P.O. Box: (942100) Amman (11194) Jordan
Tel: +962-6-5677234/5 Fax: +962-6-5688854
Email:uab-jordan@uabonline.org
Khartoum – Sudan: P.O. Box: (12597) Khartoum Telefax: +249-183-781742
Tunisia: P.O.BOX:1002/45 Tunis Tel: +216 71 908083 Fax: +216 71 951 419
Sana’a – Yemen: P.O. Box: 11318 Sana’ab Tel: +967 1 242328 Fax: +967 1 242305
